1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY SECTOR POLICIES AND PROGRAMS DIVISION OFFICE OF AIR QUALITY PLANNING AND STANDARDS O FFICE OF AIR AND RADIATION January 31, 2013 MEMORANDUM SUBJECT: Meeting notes for the December 13, 201 2 meeting with Stephen Woock of Weyerhaeuser FROM: Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG) TO: Docket EPA

- HQ

- OAR

- 2012

- 0640
This memorandum summarizes the meeting between Stephen Woock of Weyerhaeuser and the EPA on December 13, 2012
. This meeting was requested in response to the review of the Kraft Pulp Mills New Source Performance Standards (NSPS). The OAQPS kraft pulping NSPS review presentation is provided in Attachment 1. Meeting Attendees: J ohn Bradfield , EPA Kelley Spence, EPA Nick Swanson, EPA Stephen Woock, Weyerhaeuser
D iscussion Points :

• Subpart S and excess emission allowances update • NSPS update o Review of Attachment 1 o Weyerhaeuser noted the need to make monitoring and reporting more efficient between the other rules that impact the sector o Discussion of best practices for monitor downtime2 Attachment 2 EPA Status of the Kraft NSPS

# Status of the Kraft Pulping NSPS Review (40 CFR Subpart BB) December 13, 2012

1

# Overview of Activities

• Current Activities

– Assembly and analysis of emissions data and permit limits



# – Identification of regulatory options


# • Next Steps

– Estimate impacts of options

– Draft rule for internal review


# • Propose by May 15, 2013


# • Promulgate by March 14, 2014

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# Affected Source Projections

• Projections of new, modified, and reconstructed emission units.

• Estimate impacts for 5 years after applicability date of NSPS review (2013 proposal)

• Created inventory of DCE (and associated 

# BLO), NDCE, LK, and SDT systems from Part III ICR data

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# Affected Source Projections

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- SUBJECT TO CHANGE 4 Equipment Type Recovery furnaces LK SDT DCE NDCE Historical Data Number of units in ICR data base 43 108 131 164 New installations triggering NSPS 2 48 46 56 Modifications/reconstructions triggering NSPS 1 1 27 16 14 Total number that triggered NSPS since 1976 3 75 62 70 Average number of new installations per year (over 33 yrs) 0.06 1.45 1.39 1.70 Average number of modified/reconstructed emission units per year (over 33 yrs) 0.03 0.82 0.48 0.42 Projection for Next 5 Years Projected number of new installations 2 0 7 7 8 Projected number of modified/reconstructed emission units 2 0 4 2 2 1. Any NSPS units not specifically labeled as “new” or “replacement” were considered to trigger NSPS through modification or rec onstruction, even if not specifically labeled as modified or reconstructed. 2. Calculated as the average number per year x 5 years, rounded to nearest whole number.

# Recovery Furnaces

• 151 recovery furnaces: 43 DCE, 108 NDCE

– DCEs controlled by DBESP (10), DBESP/SCBR (1), DBESP
- WPR (3), WBESP (27), and WBESP/SCBR (2)

– NDCE controlled by DBESP (78), DBESP/SCBR (1), DBESP
- WPR (13), 2
- sided DB
- WBESP (1), SCBR (2), 

# and WBESP (13)

– Counts subject to change (e.g., adjustments for recent DCE
- > NDCE conversions and/or non



# operational units)

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# Recovery Furnace PM

• Current NSPS and existing source MACT limit is 0.044 gr/dscf @ 8% O2

• MACT new limit is 0.015 gr/dscf @ 8% O2

• Permit limits:

– About half of the RFs have PM permit limits below 0.044 gr/dscf @ 8% O2

– A few pre
- NSPS units have limits above 0.044 

# (e.g., MACT PM bubble mills)

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# Recovery Furnace PM Stack Data

• 206 PM stack tests on 136 recovery furnaces

– Method 5 filterable PM (few ODEQ M5)

– 2002 to 2011 stack tests



# – Multiple tests for some furnaces

– 62 DCE tests:

• 18 DBESP, 4 DBESP
- WPR, 36 WBESP, 1 DBESP/SCBR and 3 WBESP/SCBR



# – 144 NDCE tests:

• 95 DBESP, 18 DBESP
- WPR, 22 WBESP, 7 DBESP/SCBR, 1 DB
- WBESP [2
- sided, dry and wet], and 1 SCBR
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# RF PM Stack Data Observations

• NDCE and DCE similar results for PM
• Two
- thirds of the DCEs and NDCEs have 

# performance levels at or below 0.015 gr/dscf using typical recovery furnace 

# controls such as DBESP, WBESP, or DBESP
- WPR .

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# Recovery Furnace Opacity

• 160 RF COMS data sets analyzed

– Some RFs have two COMS in separate stacks

– Primarily 6
- min average analyzed

– Some highest 6
- min average per hour or hourly average


# • Current NSPS limit is 35% opacity

– 6% of averages per quarter excluding SSM can exceed without violating standard


# • MACT new limit is 20% opacity

– 6% of quarterly operating time allowance


# • Many permits with limits below 35% opacity; 20% 

# opacity common

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# Recovery Furnace TRS

• 141 RF TRS CEMS data sets analyzed

– Primarily 12
- hour average; a few 24
- hour average for non
- NSPS furnaces


# • Current NSPS limits:

– 5 ppmdv @ 8% O 2 

# [ straight RF]; 25 ppmdv @ 8% O 2 

# [ cross RF]

– Allowance for 1% of quarterly averages to exceed limit


# • Only 1 “cross” recovery furnace exists, and it is subject to 

# the lower 5 ppm TRS limit for “straight” recovery furnaces (not 25 ppm )
• Straight RF NSPS limit based on use of process controls and NDCE or process controls and 2
- stage BLO for DCE


# • Most NDCEs have 5 ppm TRS permit limit and most DCEs have 20 ppm limit (emission guidelines)

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# Lime Kilns

• 131 lime kilns

– Controls include Scrubber (92), ESP (29) and ESP/scrubber (10)


# • Use of ESP and ESP/scrubber systems is a development since 1986 NSPS review

– Reviewing monitoring options to include in the NSPS for these systems

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# Lime Kiln PM

• Current limits (all @ 10% O 2 

# ):

– NSPS: 0.066 gr/dscf (gas) and 0.13 gr/dscf (oil)

– MACT (Subpart MM):

• Existing: 0.064 gr/ dscf
• New: 0.010 gr/dscf


# • Gas/oil and gas/pet coke combinations are not addressed in the current NSPS
• Test data do not show a clear distinction in 

# fuel type vs. PM emissions

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# Lime Kiln PM Stack Data

• 255 PM stack tests on 110 kilns reviewed

– Method 5 filterable PM

– 2001 to 2011 stack tests

– ESP (113), ESP/scrubber (26), and scrubber (116) controls



# – Gas (111), oil (55), gas/oil (9), gas/pet coke (13), and unspecified (67) fuels

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# Kiln PM Stack Data Observations

• ESP and ESP/scrubber controls out

- perform scrubbers alone and are the only systems expected to achieve a new source limit of 0.01 (the MACT new limit ).

• The majority of kilns with ESP and 

# ESP/scrubber meet performance levels of 0.01, regardless of permitted limit.

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# Lime Kiln Opacity (ESP Control)

• NSPS currently specifies no LK ESP monitoring requirements

• 20% opacity required in majority of permits

• MACT requires 20% opacity

– 6% of quarterly operating time allowance


# • 29 LK COMS data sets analyzed

– Primarily 6
- min average; two hourly average



# – Included COMS on 5 ESP/scrubber systems

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# Lime Kiln TRS

• 112 TRS CEMS data sets analyzed

– Primarily 12
- hour average

– S ome 24
- hour average (e.g., non
- NSPS kilns)


# • Current NSPS limit is 8 ppmdv @ 10% O2

– Based on process control, good mud washing, and caustic scrubbing



# – No allowance for exceedances


# • Approximately half of the units have a permit limit of 8 ppmdv and half have limits of 20 ppmdv (emission guidelines)

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# Smelt Dissolving Tanks (SDTs)

• 164 SDTs

– Controlled by mist eliminator (5), scrubber (156), or incineration in recovery furnace (3)

– Incineration control is a new development since the 1986 NSPS review, but no PM or TRS test data 

# are available to determine performance (co
mingled exhaust)


# • Scrubbers are predominant control

• Monitor scrubber parameters (not opacity)

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# SDT PM and TRS Stack Data

• PM and TRS limits are in lb/ton BLS

– Needed tests with production data to compare to limits


# • 182 PM stack tests reviewed

– Method 5 filterable PM



# – 2001 to 2011 stack tests

– 4 mist eliminator, 20 packed bed scrubber, and 158 scrubber tests 

# • 100 TRS stack tests reviewed

– Methods 16 or 16A/B/C

– 1987 to 2011 (all but 7 tests were 2004 or more recent)

– Emissions converted to “as H2S” basis consistent with NSPS limit



# – 91 scrubber, 6 packed bed scrubber, and 3 mist eliminator tests


# • No stack data for SDTs venting through recovery furnaces

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# Smelt Dissolving Tank PM

• NSPS and MACT (existing) limit is 0.2 lb/ton BLS
• MACT (new) limit is 0.12 lb/ton BLS

• Permit limits:

– Most SDTs have limits of 0.2 lb/ton BLS

– About 20 percent of SDTs have limits below 0.2; most around 0.12 lb/ton BLS

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# Smelt Dissolving Tank TRS

• Original NSPS limit was 0.0168 lb/ton BLS

• During the 1986 NSPS review the limit was 

# increased to 0.033 lb “as H2S”/ton BLS

• Emission guideline document developed prior to 1986 NSPS review had 0.0168 lb/ton BLS



# • Most SDTs have permit limits of 0.033

– Approximately 20% of the units are required to 

# meet 0.0168 lb/ton BLS

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